⚡ INDUSTRIAL DR

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 173 26.0_21.0 (Industrial Dr, Plymouth County, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale BESS project on a 13.55-acre parcel located on Industrial Drive in Plymouth County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

The subject property is located on a road named "Industrial Dr," which strongly implies it is situated within a planned industrial park. This is a significant advantage for development. Road access is presumed to be excellent, with paved, wide-radius roads designed to accommodate semi-trailers and heavy construction vehicles. Delivery of large equipment, including 40-foot battery containers, switchgear, and main power transformers, is anticipated to be feasible without major road modifications. Topography in this region of Massachusetts is typically characterized by gentle, rolling hills of the Atlantic coastal plain. We expect the site to be relatively flat, minimizing the need for extensive civil work and grading, which helps control construction costs. However, a formal topographic survey is required for verification.

A primary concern is access for the electrical interconnection. The nearest identified Point of Interconnection (POI) at the substation is 1.2 miles away. This will necessitate securing a gen-tie easement across multiple third-party parcels and potentially public rights-of-way. The process of negotiating and acquiring these easements can be time-consuming, costly, and introduces significant project risk if landowners are uncooperative. The feasibility and route of this gen-tie are critical unknowns that impact overall site buildability.

2. Environmental Constraints

The environmental profile of this site presents several high-risk data gaps that must be resolved immediately. The FEMA flood zone designation is unknown; any classification other than Zone X (minimal flood risk) would be a major impediment, potentially requiring costly elevated foundations for all equipment or rendering portions of the site unusable. Similarly, the presence of wetlands is unknown. Massachusetts has extremely stringent wetland protection laws (the Massachusetts Wetlands Protection Act), which mandate significant buffers (typically 100 feet) from delineated wetland boundaries. The discovery of wetlands could severely curtail the buildable acreage and compromise the project layout.

On a positive note, initial database searches show no critical habitats for endangered species, protected areas, or nearby brownfield/superfund sites. The absence of environmental contamination reduces liability risk, but it also means the project is ineligible for the 10% IRA brownfield tax credit adder. The site is not within the Chesapeake Bay Critical Area, and there are no pipelines in the immediate vicinity, which eliminates a key safety and setback consideration.

3. Grid Infrastructure & Interconnection

The site is located 1.2 miles from a 115kV substation operated by NSTAR Electric Company (now Eversource), the likely interconnecting utility. The regional transmission operator is ISO New England (ISO-NE). For a distribution-scale project (≤5MW), a direct interconnection at 115kV would be economically unviable due to the high cost of a high-voltage switchyard and protection equipment (likely exceeding $5 million). The recommended strategy is to identify a 3-phase distribution feeder (e.g., 13.8kV or 23kV) originating from this substation that runs along Industrial Drive or adjacent to the property. The presence of an industrial park makes it highly probable that such a feeder exists.

If a suitable distribution feeder is available nearby, the interconnection cost would be primarily for the 1.2-mile gen-tie line. We estimate this could range from $1.0M to $2.5M, depending on the route, property crossings, and whether it is constructed overhead or underground. The ISO-NE interconnection process is notoriously long and complex, with queue